TMI Blog2022 (7) TMI 64X X X X Extracts X X X X X X X X Extracts X X X X ..... are applicable with effect from 1st April 2021 before issuance of notices under section 148 of the 1961 Act on or after 1st April 2021 - HELD THAT:- In considered view that this case clearly falls under the amended Act relating to proceedings under section 147 of the Act under which issuance of notice under section 148A of the Act is mandatory before issuing any notice under section 148 of the ame ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lwal Hossain Mr. Binayak Gupta for the petitioner Mr. Amit Sharma for the respondents ORDER Heard learned advocates appearing for the respective parties. Petitioner in this writ petition is aggrieved by the issuance of impugned notice under section 148 of the Income Tax Act, 1961 on the grounds that the same is barred by limitation and that the respondent-income tax authority ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1, 2021 at 3 a.m. which has to be treated as date of issuance of the impugned notice. Considering these facts, I am of the considered view that this case clearly falls under the amended Act relating to proceedings under section 147 of the Act under which issuance of notice under section 148A of the Act is mandatory before issuing any notice under section 148 of the amended Act which has not be ..... X X X X Extracts X X X X X X X X Extracts X X X X
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